Sumner v. Shuman

1987-06-22

Headline: Court strikes down mandatory death sentence for inmates serving life without parole who kill in prison, requiring individualized consideration of mitigating evidence and changing how such inmates are sentenced.

Holding: The Court ruled that a statute requiring an automatic death sentence for an inmate serving life without parole convicted of murder violates the Eighth and Fourteenth Amendments and must allow individualized consideration of mitigating evidence.

Real World Impact:

Invalidates mandatory death penalty laws that bar consideration of mitigating evidence for life-term inmates.
Requires sentencers to consider any relevant mitigating circumstances before imposing death.
Leaves states able to hold new penalty hearings under guided-discretion procedures.

Topics: death penalty, sentencing rules, prison murders, mitigating evidence

Summary

Background

Raymond Shuman, a Nevada prisoner originally sentenced in 1958 to life without parole for a murder, later killed a fellow inmate in 1975. Nevada law in effect then made any murder by a person serving life without parole a capital offense and required the death penalty. Shuman was convicted under that statute, received a mandatory death sentence, and after state appeals he challenged the sentence in federal court.

Reasoning

The central question was whether a statute that automatically imposes death on a life-term inmate who commits murder violates the Eighth and Fourteenth Amendments. The Court held that it does. The majority explained that the statute denied any chance to consider mitigating facts about the defendant or the crime, that the two statutory elements (being a life-term inmate and committing murder) do not show how much moral blame the individual bears, and that deterrence or retribution arguments did not justify dispensing with individualized sentencing.

Real world impact

The decision invalidates the Nevada mandatory provision as unconstitutional and affirms that sentencing authorities must be allowed to hear any relevant mitigating evidence before imposing death. The opinion allows States to hold new penalty proceedings under constitutionally guided sentencing procedures and reinforces the Court’s prior guidance favoring individualized capital sentencing.

Dissents or concurrances

Justice White (joined by the Chief Justice and Justice Scalia) dissented, arguing the Constitution does not forbid a legislature from making the death penalty mandatory in this narrow class of cases and that deterrence and retribution could justify such a rule.